Emergency Response

Changes to Chlorine – 2024 ERG Table 3

This is just an FYI to my Cl2 clients. Although the changes are NOT significant (0.1 – 0.3 miles), they are indeed changes to the Downwind Protective Action Distances. If you have used the 2020 ERG Distances in your Pre-Plans, which you or I did for your Emergency Response Plan (ERP), it may be beneficial…...

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Changes to Anhydrous Ammonia – 2024 ERG Table 3

This is just an FYI to my NH3 clients. Although the changes are NOT significant (0.1 – 0.2 miles), they are indeed changes to the Downwind Protective Action Distances. If you have used the 2020 ERG Distances in your Pre-Plans that you or I did for your Emergency Response Plan (ERP), it may be beneficial…...

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2024 ERG – CONSIDERATIONS FOR LITHIUM BATTERY AND ELECTRIC VEHICLE (EV) FIRES FIRE CONTROL

One of the many changes to the 2024 ERG, includes considerations for lithium battery and electric vehicle (EV) fires fire control.  NOTE: the print editions are NOT yet available, but we can download the app (CLICK HERE)   Water spray cools batteries and helps suppress and slow the release of toxic gases but does not…...

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EPA’s Clean Water Act Hazardous Substance Facility Response Plans

On March 28, 2024, the U.S. Environmental Protection Agency (EPA) published its Final Rule: Clean Water Act Hazardous Substance Facility Response Plans (Final Rule), requiring certain facilities to develop Facility Response Plans (FRP) for a worst-case discharge of Clean Water Act (CWA) hazardous substances, or threat of such a discharge. A worst-case discharge is the…...

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A DECON practice challenge

I have been involved with emergency response for over 30 years. During those years, I trained thousands of municipal and private responders, specializing in traditional Hazardous Materials Responses. During all those years, when I received continuing training from the likes of Texas A&M, LSU, NFA, and SERTC, these advanced courses only validated my first HAZWOPER…...

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2024 DOT ERG is coming!

DOT/PHMSA have compiled the most important changes from ERG2020 to ERG2024, organized by the color of the corresponding section in the guidebook White Yellow/Blue Orange, and Green In addition to the changes listed below, all sections have undergone minor editorial changes for accuracy and consistency. In this edition, DOT/PHMSA has added QR codes to the back…...

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Why Level B is the MINIMUM for 1st Entry

It comes from this requirement in OSHA’s HAZWOPER standard and has sound logic behind it… (emphasis by me) 1910.120(q)(3)(iv) Employees engaged in emergency response and exposed to hazardous substances presenting an inhalation hazard or potential inhalation hazard shall wear positive pressure self-contained breathing apparatus while engaged in emergency response, until such time that the individual…...

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Emergency Use Only SCBA and 90% Full

This week, I conducted a 24-hr HAZMAT Tech course for a client.  The facility had purchased some new SCBA cylinders, and we noticed an odd difference between two of the cylinders.  One cylinder was manufactured in 2021, and one was manufactured in early 2022, just six months apart.  As I was covering the requirements for…...

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FRA requiring Emergency Escape Breathing Apparatus (EEBA) on some locomotives

FRA is amending its regulations related to occupational noise exposure in three (3) ways. Special NOTE:  although I agree with this new requirement, it will be virtually impossible for the railroads to comply by March 2024.  There are NOT enough EEBAs in inventory to supply the Class 1s.  Then there is the written program and…...

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Understanding why we have 1910.165(b)(3) (all pun intended)

1910.165(b)(3) The employee alarm shall be distinctive and recognizable as a signal to evacuate the work area or to perform actions designated under the emergency action plan.   After an employee becomes aware of an emergency situation, the next step involves actions to be performed by that employee. Generally, the actions include evacuation or emergency…...

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